In order for us to provide you with the best possible advice and offers on financial products, we, Netsoft Media Sdn Bhd (“Netsoft Media”, “Xapp”, “we”, “us” or “our”) will be processing your Personal Data when you register on our website, Xapp.my. Therefore, we have put together a Privacy Policy and Notice that guides how Xapp will collect, record, hold, disclose, transfer and store your Personal Data. All of these activities are essential for our business so that we keep this great service completely free for you to use.

Please take some time to read our Privacy Policy and Notice so that you understand your rights on the matter.

1. Collection and Use of Personal Data

Your Personal Data is information that relates directly or indirectly to you, who is identified or identifiable from that information or from that and other information. This includes any sensitive personal data, political opinion, religious belief or any other beliefs. During the course of your transaction and dealings with Xapp, you may be requested to furnish your Personal Data from time to time. Xapp and its third party service providers may share the Personal Data with each other and use it consistent with this Privacy Policy and Notice. They may also combine it with other information to provide and improve Xapp’s products and services.

2. Personal Data that Xapp may collect

When you register to become a user of Xapp’s website, we may collect a variety of your Personal Data, which may include your:

1. Name;
2. National registration identity card number;
3. Gender;
4. Race, ethnic origin and religious beliefs;
5. Postal address;
6. Telephone number (home, mobile, office);
7. Email address;
8. Contact preferences;
9. Age;
10. Employer details and / or supporting documents;
11. Occupation;
12. Physical or mental health or medical condition;
13. Social Media account Username;
14. Frequency of travel;
15. Mobile line / Carrier provider;
16. Banking needs & preferences;
17. Preferred media channels;
18. Insurance needs & preferences;
19. Marital status;
20. Residential status;
21. Business ownership and / or supporting documents;
22. Business products, goods and services;
23. Investment preferences;
24. Location Data;
25. Family and household information and Credit card details;
26. Physical or Digital Signatures;
27. Biometric Identifiers (such as thumbprints or voice identification) and URL;
28. Information on commission or alleged commission of any offence or proceedings for any offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings.

 

The list of Personal Data stated above is not exhaustive and may include other personal data depending on the nature of dealings or transaction. The request for these other personal data will be indicated on the relevant form that you need to fill in, depending on the nature of the dealings or transactions, and for which you would need to give consent to prior to us processing the same.

3. How Xapp use your Personal Data

Your Personal Data that Xapp collect allows us to process the necessary transaction in relation to our services that you have opted for. Listed below are details of how Xapp use your personal data.

3.1 Xapp collects, uses discloses, and otherwise processes your Personal Data for the following purposes:

1. responding to your queries and requests; and responding to complaints;
2. managing the infrastructure and our business operations and complying with our internal policies and procedures;
3. verifying your identity;
4. protecting and enforcing our contractual and legal rights and obligations;
5. conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
6. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/ or
7. any other purpose relating to any of the above.

 

3.2 In addition, Xapp may collect, use, disclose and otherwise process your Personal Data for the following purposes, depending on the nature of our relationship with you:

1. if you have a subscription or membership account with Xapp;
2. to optimize and customize your user experience with our website;
3. to process your application for online subscription services;
4. to maintain your account with us;
5. to verify and process your personal details and payments in relation to provision of online subscription service to you;
6. to provide you with the services which you have signed up for;
7. to provide you the products which you have paid for;
8. to keep you posted on Xapp's latest services or product announcements and upcoming events.
9. resolving complaints and handling requests and enquiries;
10. conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you;
11. to send important notices, emails, letters or short messaging service (SMS), like communications about purchases and changes to Xapp’ terms, conditions, and policies.
12. to share your Personal Data with third party providers for the purposes of (but not limited to) fulfillment of customer orders, processing and delivery of financial products to you.
13. for any of the purposes relating to the above.

 

You hereby agree and understand that collection and processing of your Personal Data by Xapp is not limited to facilitating the visualisation and subsequent publication of your business mobile application. The purpose of such collection and retention and otherwise processing of Personal Data is towards Xapp’s partnering/assisting you in your business journey. In order to assist you with other business ventures in the future, we will retain your data even after the completion of the transaction. By filling in your Personal Data on our website, you expressly consent for the retention of the same. If you do not wish to have your Personal Data on our website, you may opt out by contacting us.

4. Impact Resulting from Failure to Supply Data

The failure to supply Personal Data may affect our ability to deliver optimised user experience service to our registered users. In addition, failure to provide certain essential Personal Data may result in us being unable to provide you with the services and/or products that you have opted for.

5. Disclosure of Personal Data

Personal Data provided to us will generally be kept confidential but you hereby consent and authorize us to provide or disclose your Personal Data to the following categories of parties:

1. any person or authority to whom we are compelled or required to do so under law, court order or in response to a competent or government agency;
2. any relevant financial institutions or banks that provide financial related products or services that are referred to them by us or that are featured on our website;
3. our business partners and online affiliates that provide the services that you have opted for or related services or products in connection with our website including, but not limited to market research firms, third party marketing entities, entities engaged in the financial related services, telecommunications, technology and car industry;
4. members of our Group companies and their affiliates;
5. government agencies and industry regulators;
6. our auditors, consultants, accountants, lawyers or other financial or professional advisers; and;
7. such sub-contractors or third party service or product providers as we may determine to be necessary or appropriate.

 

6. Protection of Personal Data

Xapp takes the necessary precautions, both administrative and technical to safeguard your Personal Data against loss, theft, misuse and unauthorized access, disclosure, usage, alteration or destruction. Xapp ensures that all information collected will be safely and securely stored.

7. Retention of Personal Data and Access

Xapp shall endeavour to make it easy for you to keep your Personal Data accurate, complete and up to date. We will retain your Personal Data for the period necessary to fulfill the many different purposes outlined in this Privacy Policy and Notice unless a longer retention period is permitted or required by law. You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging into Xapp’s website at www.publicgo.my or by contacting us. For other personal information, we make good faith efforts to provide you with access so you can request that we correct the data if it is inaccurate or delete the data if Xapp is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

8. Collection of Computer Data not necessarily Personal Data

When you visit Xapp, our servers will automatically record information that your browser sends whenever you visit a website. This information may include:

1. Your device’s IP address;
2. Browser type;
3. Cookies;
4. Webpage you were visiting before you came to our website;
5. The pages within Xapp that you visit;
6. The time spent on those pages, products and information searched for on our site, access times and dates, and other statistics

 

This information is collected for analysis and evaluation in order to help us improve our website and products we provide. Said information may be used in association with any other Personal Data.

9. Cookies

In order for Xapp to improve on the quality of its services and products as well as to customise user experience, we may track user behaviour on its websites by using “Cookies”. A cookie is a small text file that is stored on your computer that provide us with information about your online use of our website to help us customise your user experience and make our website more user friendly.

Website visitors who have yet to register as our user or have yet to log in as a user will be tracked anonymously. The data collected from such tracking will be generic and aggregated in nature and no individual data will be collected therefrom. In respect of registered users, Xapp will use cookies to gather data on our user’s preferences provided that such cookies are secure in nature and based on HTTP only.

If you have set your web browser to warn you before accepting cookies, you should receive a notice message with each cookie. You may decline the use of cookies by opting to turn them off in your web browser but please note that in doing so, this may affect our ability to render the best user experience on our website.

10. Data Transfer & Sharing

Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your Personal Data to another member of our Group companies or third party service or product providers within or outside the country in which we are established, under conditions of confidentiality and similar levels of security safeguards.

11. Your Rights of Access and Correction; and Rights of Withdrawal of Consent

1. You have the right to request access to and correction of data about you held by us and in this respect, you may:
2. check whether we hold or use your Personal Data and request access to such data;

 

1. request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;
2. request that your Personal Data is retained by us only as long as necessary for the fulfilment of the purposes for which it was collected;
3. request that we specify or explain our policies and procedures in relation to data and types of Personal Data handled by us; and;
4. communicate to us your objection to the use of your Personal Data for marketing purposes whereupon we will not use your Personal Data for these purposes. Your non-consent may curtail our ability to perform some or all of the Purposes for which we have first collected your Personal Data; and;
5. withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.

12. Visiting Our Website from Outside Malaysia

This Privacy Policy and Notice is intended to cover collection of information a on Website from residents of Malaysia. If you are visiting Website from outside Malaysia, please be aware that your information may be transferred to, stored and processed where our servers are located. The data protection and other laws of Malaysia might not be as comprehensive as those in your country. Please be assured that we take reasonable measures to ensure that your privacy is protected.

13. Other Matters

If you have any questions regarding this policy, please contact us.

14. Xapp reserves the right to update and amend this Policy and Notice from time to time. Any material changes will be posted on our website with the updated Privacy Policy and Notice.